Privacy Policy
Effective 5 October 2026
1. Our two roles
- Controller of account and usage data: information about clinic staff and account holders that we need to run, secure and bill the service.
- Processor of Clinic Data: patients, visits, results, prescriptions, invoices and other records a clinic enters. The Data Processing Agreement governs that data. Patients who want to exercise their rights should contact the clinic that treated them first.
2. What we collect
- Account data: name, work email, phone, role, department and professional licence number entered for staff.
- Security and usage data: sign-in times, IP address, device and browser, and an audit trail of the records each user viewed or changed.
- Billing data: the organization's plan, invoices and payment status. Card or mobile-money details are handled by our payment provider and never stored by Medisphere.
- Support data: messages you send us and the details needed to resolve them.
3. Why we use it, and on what basis
- To provide the service to your organization (performance of our contract).
- To secure accounts, detect misuse and keep audit logs (legitimate interest, and the clinic's legal duty to protect health data).
- To bill the organization and keep accounting records (legal obligation).
- To send service notices, such as security alerts or changes to these policies. We do not send marketing to staff accounts without consent.
4. Health data
Health data is sensitive personal data under Rwandan law. Inside a clinic, each staff member sees only the records their permissions allow, and every access and change is logged. Medisphere personnel access Clinic Data only when the clinic asks for support, or to investigate a security incident, and that access is logged as well.
5. Who we share data with
We do not sell personal data. We share it only with subprocessors that help run the service, such as hosting, email and SMS delivery, and payment processing. Each one is bound by a contract requiring equivalent protection. We disclose data to authorities only when Rwandan law requires it, and we tell the affected clinic unless the law forbids us.
6. Where data is stored
We store and process personal data in Rwanda or, where a provider is located abroad, only as permitted by Article 50 of Law No. 058/2021. That means holding the registration required from the National Cyber Security Authority (NCSA) and keeping safeguards in place that give equivalent protection.
7. How long we keep it
- Account data: for as long as the account is active, then up to 12 months for security and dispute purposes.
- Audit and sign-in logs: as long as the clinic's subscription lasts, so the clinic can investigate access to records.
- Clinic Data: as instructed by the clinic. After an account closes, it stays available for export for 90 days and is then deleted, unless the law requires a longer period.
8. Your rights
Under Law No. 058/2021 you have the right to be informed, to access your personal data, to have it corrected or erased, to object to or restrict its processing, to data portability, and not to be subject to decisions based solely on automated processing. Send requests to privacy@medisphere.com. We reply within 30 days. If you are not satisfied, you may complain to the National Cyber Security Authority.
9. Children
Clinics record data about children as part of their care. Where consent is the basis for processing a child's data, the clinic records the consent of a parent or legal guardian on the patient's profile.
10. Security
See Data Protection for the safeguards we apply and how we handle security incidents.
11. Changes and contact
When this policy changes materially we update the effective date and ask users to review it at their next sign-in. For privacy questions, write to privacy@medisphere.com.